State Of New York et al v. Mnuchin et al
Filing
47
DECLARATION of Owen T. Conroy in Support re: 44 CROSS MOTION for Summary Judgment .. Document filed by State Of Connecticut, State Of New York, State of Maryland, State of New Jersey. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34, # 35 Exhibit 35, # 36 Exhibit 36, # 37 Exhibit 37, # 38 Exhibit 38, # 39 Exhibit 39, # 40 Exhibit 40, # 41 Exhibit 41, # 42 Exhibit 42, # 43 Exhibit 43, # 44 Exhibit 44, # 45 Exhibit 45, # 46 Exhibit 46, # 47 Exhibit 47, # 48 Exhibit 48, # 49 Exhibit 49, # 50 Exhibit 50, # 51 Exhibit 51, # 52 Exhibit 52, # 53 Exhibit 53, # 54 Exhibit 54, # 55 Exhibit 55, # 56 Exhibit 56, # 57 Exhibit 57, # 58 Exhibit 58, # 59 Exhibit 59, # 60 Exhibit 60, # 61 Exhibit 61, # 62 Exhibit 62, # 63 Exhibit 63, # 64 Exhibit 64, # 65 Exhibit 65, # 66 Exhibit 66, # 67 Exhibit 67, # 68 Exhibit 68, # 69 Exhibit 69, # 70 Exhibit 70, # 71 Exhibit 71, # 72 Exhibit 72, # 73 Exhibit 73, # 74 Exhibit 74, # 75 Exhibit 75, # 76 Exhibit 76, # 77 Exhibit 77, # 78 Exhibit 78, # 79 Exhibit 79, # 80 Exhibit 80, # 81 Exhibit 81, # 82 Exhibit 82, # 83 Exhibit 83, # 84 Exhibit 84, # 85 Exhibit 85, # 86 Exhibit 86, # 87 Exhibit 87, # 88 Exhibit 88, # 89 Exhibit 89, # 90 Exhibit 90, # 91 Exhibit 91, # 92 Exhibit 92, # 93 Exhibit 93, # 94 Exhibit 94, # 95 Exhibit 95, # 96 Exhibit 96, # 97 Exhibit 97, # 98 Exhibit 98, # 99 Exhibit 99, # 100 Exhibit 100, # 101 Exhibit 101, # 102 Exhibit 102, # 103 Exhibit 103, # 104 Exhibit 104, # 105 Exhibit 105, # 106 Exhibit 106)(Conroy, Owen)
Exhibit 82
PUBLIC LAW 113–295—DEC. 19, 2014
128 STAT. 4013
(b) EFFECTIVE DATE.—The amendment made by this section
shall apply to taxable years beginning after December 31, 2013.
26 USC 62 note.
SEC. 102. EXTENSION OF EXCLUSION FROM GROSS INCOME OF DISCHARGE OF QUALIFIED PRINCIPAL RESIDENCE INDEBTEDNESS.
(a) IN GENERAL.—Subparagraph (E) of section 108(a)(1) is
amended by striking ‘‘January 1, 2014’’ and inserting ‘‘January
1, 2015’’.
(b) EFFECTIVE DATE.—The amendment made by this section
shall apply to indebtedness discharged after December 31, 2013.
26 USC 108.
26 USC 108 note.
SEC. 103. EXTENSION OF PARITY FOR EMPLOYER-PROVIDED MASS
TRANSIT AND PARKING BENEFITS.
(a) IN GENERAL.—Paragraph (2) of section 132(f) is amended
by striking ‘‘January 1, 2014’’ and inserting ‘‘January 1, 2015’’.
(b) EFFECTIVE DATE.—The amendment made by this section
shall apply to months after December 31, 2013.
26 USC 132 note.
SEC. 104. EXTENSION OF MORTGAGE INSURANCE PREMIUMS TREATED
AS QUALIFIED RESIDENCE INTEREST.
(a) IN GENERAL.—Subclause (I) of section 163(h)(3)(E)(iv) is
amended by striking ‘‘December 31, 2013’’ and inserting ‘‘December
31, 2014’’.
(b) EFFECTIVE DATE.—The amendment made by this section
shall apply to amounts paid or accrued after December 31, 2013.
26 USC 163 note.
SEC. 105. EXTENSION OF DEDUCTION OF STATE AND LOCAL GENERAL
SALES TAXES.
(a) IN GENERAL.—Subparagraph (I) of section 164(b)(5) is
amended by striking ‘‘January 1, 2014’’ and inserting ‘‘January
1, 2015’’.
(b) EFFECTIVE DATE.—The amendment made by this section
shall apply to taxable years beginning after December 31, 2013.
26 USC 164 note.
SEC. 106. EXTENSION OF SPECIAL RULE FOR CONTRIBUTIONS OF CAPITAL GAIN REAL PROPERTY MADE FOR CONSERVATION
PURPOSES.
(a) IN GENERAL.—Clause (vi) of section 170(b)(1)(E) is amended
by striking ‘‘December 31, 2013’’ and inserting ‘‘December 31, 2014’’.
(b) CONTRIBUTIONS BY CERTAIN CORPORATE FARMERS AND
RANCHERS.—Clause (iii) of section 170(b)(2)(B) is amended by
striking ‘‘December 31, 2013’’ and inserting ‘‘December 31, 2014’’.
(c) EFFECTIVE DATE.—The amendments made by this section
shall apply to contributions made in taxable years beginning after
December 31, 2013.
26 USC 170 note.
SEC. 107. EXTENSION OF ABOVE-THE-LINE DEDUCTION FOR QUALIFIED TUITION AND RELATED EXPENSES.
(a) IN GENERAL.—Subsection (e) of section 222 is amended
by striking ‘‘December 31, 2013’’ and inserting ‘‘December 31, 2014’’.
(b) EFFECTIVE DATE.—The amendment made by this section
shall apply to taxable years beginning after December 31, 2013.
26 USC 222 note.
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SEC. 108. EXTENSION OF TAX-FREE DISTRIBUTIONS FROM INDIVIDUAL
RETIREMENT PLANS FOR CHARITABLE PURPOSES.
(a) IN GENERAL.—Subparagraph (F) of section 408(d)(8) is
amended by striking ‘‘December 31, 2013’’ and inserting ‘‘December
31, 2014’’.
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128 STAT. 4028
26 USC 6722.
26 USC 6722
note.
PUBLIC LAW 113–295—DEC. 19, 2014
(3) Subparagraph (B) of section 6722(c)(2) is amended by
striking ‘‘filed’’ and inserting ‘‘furnished’’.
(b) EFFECTIVE DATE.—The amendments made by this section
shall take effect as if included in the provision of the Creating
Small Business Jobs Act of 2010 to which they relate.
SEC. 208. CLERICAL AMENDMENT RELATING TO HIRING INCENTIVES
TO RESTORE EMPLOYMENT ACT.
26 USC 6662.
26 USC 6662
note.
(a) AMENDMENT RELATING TO SECTION 512.—Paragraph (1) of
section 512(a) of the Hiring Incentives to Restore Employment
Act is amended by striking ‘‘after paragraph (6)’’ and inserting
‘‘after paragraph (5)’’.
(b) EFFECTIVE DATE.—The amendment made by this section
shall take effect as if included in the provision of the Hiring Incentives to Restore Employment Act to which it relates.
SEC. 209. AMENDMENTS RELATING TO AMERICAN RECOVERY AND
REINVESTMENT TAX ACT OF 2009.
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Time period.
Applicability.
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(a) AMENDMENT RELATING TO SECTION 1003.—Paragraph (4)
of section 24(d) is amended to read as follows:
‘‘(4) SPECIAL RULE FOR CERTAIN YEARS.—In the case of
any taxable year beginning after 2008 and before 2018, paragraph (1)(B)(i) shall be applied by substituting ‘$3,000’ for
‘$10,000’.’’.
(b) AMENDMENT RELATING TO SECTION 1004.—Paragraph (3)
of section 25A(i) is amended by striking ‘‘Subsection (f)(1)(A) shall
be applied’’ and inserting ‘‘For purposes of determining the Hope
Scholarship Credit, subsection (f)(1)(A) shall be applied’’.
(c) AMENDMENTS RELATING TO SECTION 1008.—
(1) Paragraph (6) of section 164(b) is amended by striking
subparagraph (E) and by redesignating subparagraphs (F) and
(G) as subparagraphs (E) and (F), respectively.
(2) Subparagraphs (E) and (F) of section 164(b)(6), as so
redesignated, are each amended by striking ‘‘This paragraph’’
and inserting ‘‘Subsection (a)(6)’’.
(d) AMENDMENT RELATING TO SECTION 1104.—Subparagraph
(A) of section 48(d)(3) is amended by inserting ‘‘or alternative minimum taxable income’’ after ‘‘includible in the gross income’’.
(e) AMENDMENTS RELATING TO SECTION 1141.—
(1) Subsection (f) of section 30D is amended—
(A) by inserting ‘‘(determined without regard to subsection (c))’’ before the period at the end of paragraph
(1), and
(B) by inserting ‘‘(determined without regard to subsection (c))’’ before the period at the end of paragraph
(2).
(2) Paragraph (3) of section 30D(f) is amended by adding
at the end the following: ‘‘For purposes of subsection (c), property to which this paragraph applies shall be treated as of
a character subject to an allowance for depreciation.’’.
(f) AMENDMENTS RELATING TO SECTION 1142.—
(1) Subsection (b) of section 38 is amended by striking
‘‘plus’’ at the end of paragraph (35), by redesignating paragraph
(36) as paragraph (37), and by inserting after paragraph (35)
the following new paragraph:
‘‘(36) the portion of the qualified plug-in electric vehicle
credit to which section 30(c)(1) applies, plus’’.
(2)(A) Subsection (e) of section 30 is amended—
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PUBLIC LAW 113–295—DEC. 19, 2014
128 STAT. 4037
(z) Subsection (a) of section 9035 is amended by striking ‘‘section
320(b)(1)(A)’’ and inserting ‘‘section 315(b)(1)(A)’’.
(aa) Section 9802 is amended by redesignating the second subsection (f) (relating to genetic information of a fetus or embryo)
as subsection (g).
(bb) Paragraph (3) of section 13(e) of the Worker, Homeownership, and Business Assistance Act of 2009 is amended by striking
‘‘subsection (d)’’ and inserting ‘‘subsection (c)’’.
26 USC 9035.
26 USC 56 note.
SEC. 221. DEADWOOD PROVISIONS.
(a) IN GENERAL.—
(1) ADJUSTMENTS
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IN TAX TABLES SO THAT INFLATION WILL
NOT RESULT IN TAX INCREASES.—Paragraph (7) of section 1(f)
is amended to read as follows:
‘‘(7) SPECIAL RULE FOR CERTAIN BRACKETS.—In prescribing
tables under paragraph (1) which apply to taxable years beginning in a calendar year after 1994, the cost-of-living adjustment
used in making adjustments to the dollar amounts at which
the 36 percent rate bracket begins or at which the 39.6 percent
rate bracket begins shall be determined under paragraph (3)
by substituting ‘1993’ for ‘1992’.’’.
(2) CERTAIN PLUG-IN ELECTRIC VEHICLES.—
(A) Subpart B of part IV of subchapter A of chapter
1 is amended by striking section 30 (and by striking the
item relating to such section in the table of sections for
such subpart).
(B) Subsection (b) of section 38, as amended by section
209(f)(1) of this Act, is amended by inserting ‘‘plus’’ at
the end of paragraph (35), by striking paragraph (36),
and by redesignating paragraph (37) as paragraph (36).
(C) Subclause (VI) of section 48C(c)(1)(A)(i) is amended
by striking ‘‘, qualified plug-in electric vehicles (as defined
by section 30(d)),’’.
(D) Section 1016(a) is amended by striking paragraph
(25).
(E) Section 6501(m) is amended by striking ‘‘section
30(e)(6),’’.
(3) EARNED INCOME CREDIT.—
(A) Paragraph (1) of section 32(b) is amended—
(i) by striking subparagraphs (B) and (C), and
(ii) by striking ‘‘(A) IN GENERAL.—In the case of
taxable years beginning after 1995:’’ in subparagraph
(A) and moving the table 2 ems to the left.
(B) Subparagraph (B) of section 32(b)(2) is amended
by striking ‘‘increased by’’ and all that follows and inserting
‘‘increased by $3,000.’’.
(4) FIRST-TIME HOMEBUYER CREDIT.—Section 6213(g)(2), as
amended by section 214(a)(2) of this Act, is amended by striking
subparagraph (P).
(5) MAKING WORK PAY CREDIT.—
(A) Subpart C of part IV of subchapter A of chapter
1 is amended by striking section 36A (and by striking
the item relating to such section in the table of sections
for such subpart).
(B) Subparagraph (A) of section 6211(b)(4) is amended
by striking ‘‘, 36A’’.
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26 USC prec. 27.
26 USC prec. 31.
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128 STAT. 4038
(C) Section 6213(g)(2) is amended by striking subparagraph (N).
(6) GENERAL BUSINESS CREDITS.—Subsection (d) of section
38 is amended by striking paragraph (3).
(7) LOW-INCOME HOUSING CREDIT.—Subclause (I) of section
42(h)(3)(C)(ii) is amended by striking ‘‘($1.50 for 2001)’’.
(8) MINIMUM TAX CREDIT.—
(A)(i) Section 53 is amended by striking subsections
(e) and (f).
(ii) The amendment made by clause (i) striking subsection (f) of section 53 of the Internal Revenue Code of
1986 shall not be construed to allow any tax abated by
reason of section 53(f)(1) of such Code (as in effect before
such amendment) to be included in the amount determined
under section 53(b)(1) of such Code.
(B) Paragraph (4) of section 6211(b)(4) is amended
by striking ‘‘, 53(e)’’.
(9) ADJUSTMENTS BASED ON ADJUSTED CURRENT
EARNINGS.—Clause (ii) of section 56(g)(4)(F) is amended by
striking ‘‘In the case of any taxable year beginning after
December 31, 1992, clause’’ and inserting ‘‘Clause’’.
(10) ITEMS OF TAX PREFERENCE; DEPLETION.—Paragraph
(1) of section 57(a) is amended by striking ‘‘Effective with
respect to taxable years beginning after December 31, 1992,
this’’ and inserting ‘‘This’’.
(11) INTANGIBLE DRILLING COSTS.—
(A) Clause (i) of section 57(a)(2)(E) is amended by
striking ‘‘In the case of any taxable year beginning after
December 31, 1992, this’’ and inserting ‘‘This’’.
(B) Clause (ii) of section 57(a)(2)(E) is amended by
striking ‘‘(30 percent in case of taxable years beginning
in 1993)’’.
(12) ENVIRONMENTAL TAX.—
(A) Subchapter A of chapter 1 is amended by striking
part VII (and by striking the item relating to such part
in the table of parts for such subchapter).
(B) Paragraph (2) of section 26(b) is amended by
striking subparagraph (B).
(C) Section 30A(c) is amended by striking paragraph
(1) and by redesignating paragraphs (2), (3), and (4) as
paragraphs (1), (2), and (3), respectively.
(D) Subsection (a) of section 164 is amended by striking
paragraph (5).
(E) Section 275(a) is amended by striking the last
sentence.
(F) Section 882(a)(1) is amended by striking ‘‘, 59A’’.
(G) Section 936(a)(3) is amended by striking subparagraph (A) and by redesignating subparagraphs (B), (C),
and (D) as subparagraphs (A), (B), and (C), respectively.
(H) Section 1561(a) is amended—
(i) by inserting ‘‘and’’ at the end of paragraph
(2), by striking ‘‘, and’’ at the end of paragraph (3)
and inserting a period, and by striking paragraph (4),
and
(ii) by striking ‘‘, the amount specified in paragraph
(3), and the amount specified in paragraph (4)’’ and
inserting ‘‘and the amount specified in paragraph (3)’’.
26 USC 6213.
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26 USC
prec. 59A.
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PUBLIC LAW 113–295—DEC. 19, 2014
128 STAT. 4039
(I) Section 4611(e) is amended—
(i) by striking ‘‘section 59A, this section,’’ in paragraph (2)(B) and inserting ‘‘this section’’, and
(ii) in paragraph (3)(A)—
(I) by striking ‘‘section 59A,’’, and
(II) by striking the comma after ‘‘rate)’’.
(J) Section 6425(c)(1)(A) is amended by inserting ‘‘plus’’
at end of clause (i), by striking ‘‘plus’’ and inserting ‘‘over’’
at the end of clause (ii), and by striking clause (iii).
(K) Section 6655 is amended—
(i) in subsections (e)(2)(A)(i) and (e)(2)(B)(i), by
striking ‘‘taxable income, alternative minimum taxable
income, and modified alternative minimum taxable
income’’ and inserting ‘‘taxable income and alternative
minimum taxable income’’,
(ii) in subsection (e)(2)(B), by striking clause (iii),
and
(iii) in subsection (g)(1)(A), by inserting ‘‘plus’’ at
the end of clause (ii), by striking clause (iii), and by
redesignating clause (iv) as clause (iii).
(L) Section 9507(b)(1) is amended by striking ‘‘59A,’’.
(13) STANDARD DEDUCTION.—
(A) So much of paragraph (1) of section 63(c) as follows
‘‘the sum of—’’ is amended to read as follows:
‘‘(A) the basic standard deduction, and
‘‘(B) the additional standard deduction.’’.
(B) Subsection (c) of section 63 is amended by striking
paragraphs (7), (8), and (9).
(14) ANNUITIES; CERTAIN PROCEEDS OF ENDOWMENT AND
LIFE INSURANCE CONTRACTS.—Section 72 is amended—
(A) in subsection (c)(4), by striking ‘‘; except that if
such date was before January 1, 1954, then the annuity
starting date is January 1, 1954’’, and
(B) in subsection (g)(3), by striking ‘‘January 1, 1954,
or’’ and ‘‘, whichever is later’’.
(15) UNEMPLOYMENT COMPENSATION.—Section 85 is
amended by striking subsection (c).
(16) ACCIDENT AND HEALTH PLANS.—Section 105(f) is
amended by striking ‘‘or (d)’’.
(17) FLEXIBLE SPENDING ARRANGEMENTS.—Section 106(c)(1)
is amended by striking ‘‘Effective on and after January 1,
1997, gross’’ and inserting ‘‘Gross’’.
(18) CERTAIN COMBAT ZONE COMPENSATION OF MEMBERS
OF THE ARMED FORCES.—Subsection (c) of section 112 is
amended—
(A) by striking ‘‘(after June 24, 1950)’’ in paragraph
(2), and
(B) by striking ‘‘such zone;’’ and all that follows in
paragraph (3) and inserting ‘‘such zone.’’.
(19) LEGAL SERVICE PLANS.—
(A) Part III of subchapter B of chapter 1 is amended
by striking section 120 (and by striking the item relating
to such section in the table of sections for such subpart).
(B)(i) Section 414(n)(3)(C) is amended by striking
‘‘120,’’.
(ii) Section 414(t)(2) is amended by striking ‘‘120,’’.
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26 USC 4611.
26 USC
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128 STAT. 4040
(iii) Section 501(c) is amended by striking paragraph
(20).
(iv) Section 3121(a) is amended by striking paragraph
(17).
(v) Section 3231(e) is amended by striking paragraph
(7).
(vi) Section 3306(b) is amended by striking paragraph
(12).
(vii) Section 6039D(d)(1) is amended by striking ‘‘120,’’.
(viii) Section 209(a)(14) of the Social Security Act is
amended—
(I) by striking subparagraph (B), and
(II) by striking ‘‘(14)(A)’’ and inserting ‘‘(14)’’.
(20) PRINCIPAL RESIDENCE.—Section 121(b)(3) is amended—
(A) by striking subparagraph (B), and
(B) in subparagraph (A), by striking ‘‘(A) IN GENERAL.—
’’ and moving the text 2 ems to the left.
(21) CERTAIN REDUCED UNIFORMED SERVICES RETIREMENT
PAY.—Section 122(b)(1) is amended by striking ‘‘after December
31, 1965,’’.
(22) GREAT PLAINS CONSERVATION PROGRAM.—Section
126(a) is amended by striking paragraph (6) and by redesignating paragraphs (7), (8), (9), and (10) as paragraphs (6),
(7), (8), and (9), respectively.
(23) TREBLE DAMAGE PAYMENTS UNDER THE ANTITRUST
LAW.—Section 162(g) is amended by striking the last sentence.
(24) STATE LEGISLATORS’ TRAVEL EXPENSES AWAY FROM
HOME.—Paragraph (4) of section 162(h) is amended by striking
‘‘For taxable years beginning after December 31, 1980, this’’
and inserting ‘‘This’’.
(25) INTEREST.—
(A) Section 163 is amended—
(i) by striking paragraph (6) of subsection (d), and
(ii) by striking paragraph (5) of subsection (h).
(B) Section 56(b)(1)(C) is amended by striking clause
(ii) and by redesignating clauses (iii), (iv), and (v) as clauses
(ii), (iii), and (iv), respectively.
(26) QUALIFIED MOTOR VEHICLE TAXES.—Section 164, as
amended by section 209(c) of this Act, is amended by striking
subsections (a)(6) and (b)(6).
(27) DISASTER LOSSES.—
(A) Subsection (h) of section 165 is amended by striking
paragraph (3) and by redesignating paragraphs (4) and
(5) as paragraphs (3) and (4), respectively.
(B) Paragraph (3) of section 165(h), as so redesignated,
is amended by striking ‘‘paragraphs (2) and (3)’’ and
inserting ‘‘paragraph (2)’’.
(C) Subsection (i) of section 165 is amended—
(i) in paragraph (1)—
(I) by striking ‘‘(as defined by clause (ii) of
subsection (h)(3)(C))’’, and
(II) by striking ‘‘(as defined by clause (i) of
such subsection)’’,
(ii) by striking ‘‘(as defined by subsection
(h)(3)(C)(i)’’ in paragraph (4), and
(iii) by adding at the end the following new paragraph:
26 USC 501.
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26 USC 409.
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PUBLIC LAW 113–295—DEC. 19, 2014
128 STAT. 4041
‘‘(5) FEDERALLY DECLARED DISASTERS.—For purposes of this
subsection—
‘‘(A) IN GENERAL.—The term ‘Federally declared disaster’ means any disaster subsequently determined by the
President of the United States to warrant assistance by
the Federal Government under the Robert T. Stafford Disaster Relief and Emergency Assistance Act.
‘‘(B) DISASTER AREA.—The term ‘disaster area’ means
the area so determined to warrant such assistance.’’.
(D) Section 1033(h)(3) is amended by striking ‘‘section
165(h)(3)(C)’’ and inserting ‘‘section 165(i)(5)’’.
(28) CHARITABLE, ETC., CONTRIBUTIONS AND GIFTS.—Section
170 is amended—
(A) by striking paragraph (3) of subsection (b),
(B) by striking paragraph (6) of subsection (e), and
(C) by striking subsection (k).
(29) AMORTIZABLE BOND PREMIUM.—
(A) Subparagraph (B) of section 171(b)(1) is amended
to read as follows:
‘‘(B)(i) with reference to the amount payable on maturity (or if it results in a smaller amortizable bond premium
attributable to the period before the call date, with reference to the amount payable on the earlier call date),
in the case of a bond described in subsection (a)(1), and
‘‘(ii) with reference to the amount payable on maturity
or on an earlier call date, in the case of a bond described
in subsection (a)(2).’’.
(B) Paragraphs (2) and (3)(B) of section 171(b) are
each amended by striking ‘‘paragraph (1)(B)(ii)’’ and
inserting ‘‘paragraph (1)(B)(i)’’.
(30) NET OPERATING LOSS CARRYBACKS, CARRYOVERS, AND
CARRYFORWARDS.—
(A) Section 172, as amended by section 211(c)(1)(B)
of this Act, is amended—
(i) by striking subparagraphs (D), (H), (I), and
(J) of subsection (b)(1) and by redesignating subparagraphs (E), (F), and (G) as subparagraphs (D), (E),
and (F), respectively, and
(ii) by striking subsections (g) and (j) and by
redesignating subsections (h), (i), and (k) as subsections
(g), (h), and (i), respectively.
(B) Each of the following provisions of section 172
(as amended by section 211(c)(1)(B) of this Act and as
redesignated by subparagraph (A)) are amended as follows:
(i) By striking ‘‘ending after August 2, 1989’’ in
subsection (b)(1)(D)(i)(II).
(ii) By striking ‘‘subsection (h)’’ in subsection
(b)(1)(D)(ii) and inserting ‘‘subsection (g)’’.
(iii) By striking ‘‘section 165(h)(3)(C)(i)’’ in subsection (b)(1)(E)(ii)(II) and inserting ‘‘section 165(i)(5)’’.
(iv) By striking ‘‘subsection (i)’’ and all that follows
in the last sentence of subsection (b)(1)(E)(ii) and
inserting ‘‘subsection (h)).’’.
(v) By striking ‘‘subsection (i)’’ in subsection
(b)(1)(F) and inserting ‘‘subsection (h)’’.
(vi) By striking subparagraph (F) of paragraph
(2) of subsection (g).
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(vii) By striking ‘‘subsection (b)(1)(E)’’ each place
it appears in subsection (g)(4) and inserting ‘‘subsection
(b)(1)(D)’’.
(viii) By striking the last sentence of subsection
(h)(1).
(ix) By striking ‘‘subsection (b)(1)(G)’’ each place
it appears in subsection (h)(3) and inserting ‘‘subsection
(b)(1)(F)’’.
(C) Subsection (d) of section 56 is amended by striking
paragraph (3).
(D) Paragraph (5) of section 382(l) is amended by
striking subparagraph (F) and by redesignating subparagraphs (G) and (H) as subparagraphs (F) and (G), respectively.
(31) RESEARCH AND EXPERIMENTAL EXPENDITURES.—
Subparagraph (A) of section 174(a)(2) is amended to read as
follows:
‘‘(A) WITHOUT CONSENT.—A taxpayer may, without the
consent of the Secretary, adopt the method provided in
this subsection for his first taxable year for which expenditures described in paragraph (1) are paid or incurred.’’.
(32) AMORTIZATION OF CERTAIN RESEARCH AND EXPERIMENTAL EXPENDITURES.—Paragraph (2) of section 174(b) is
amended by striking ‘‘beginning after December 31, 1953’’.
(33) SOIL AND WATER CONSERVATION EXPENDITURES.—Paragraph (1) of section 175(d) is amended to read as follows:
‘‘(1) WITHOUT CONSENT.—A taxpayer may, without the consent of the Secretary, adopt the method provided in this section
for the taxpayer’s first taxable year for which expenditures
described in subsection (a) are paid or incurred.’’.
(34) CLEAN-FUEL VEHICLES.—
(A) Part VI of subchapter A of chapter 1 is amended
by striking section 179A (and by striking the item relating
to such section in the table of sections for such part).
(B) Section 30C(e) is amended by adding at the end
the following:
‘‘(7) REFERENCE.—For purposes of this section, any reference to section 179A shall be treated as a reference to such
section as in effect immediately before its repeal.’’.
(C) Section 62(a) is amended by striking paragraph
(14).
(D) Section 263(a)(1) is amended by striking subparagraph (H).
(E) Section 280F(a)(1) is amended by striking subparagraph (C).
(F) Section 312(k)(3) is amended by striking ‘‘179A,’’
each place it appears.
(G) Section 1016(a) is amended by striking paragraph
(24).
(H) Section 1245(a) is amended by striking ‘‘179A,’’
each place it appears in paragraphs (2)(C) and (3)(C).
(35) QUALIFIED DISASTER EXPENSES.—Part VI of subchapter
A of chapter 1 is amended by striking section 198A (and by
striking the item relating to such section in the table of sections
for such part).
(36) ACTIVITIES NOT ENGAGED IN FOR PROFIT.—Section
183(e)(1) is amended by striking the last sentence.
26 USC 56.
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128 STAT. 4043
(37) DOMESTIC PRODUCTION ACTIVITIES.—
(A) Subsection (a) of section 199 is amended—
(i) by striking paragraph (2),
(ii) by redesignating subparagraphs (A) and (B)
of paragraph (1) as paragraphs (1) and (2), respectively,
and by moving paragraphs (1) and (2) (as so redesignated) 2 ems to the left, and
(iii) by striking ‘‘ALLOWANCE OF DEDUCTION.—’’
and all that follows through ‘‘There shall be allowed’’
and inserting the following:
‘‘(a) ALLOWANCE OF DEDUCTION.—There shall be allowed’’.
(B) Paragraphs (2) and (6)(B) of section 199(d) are
each amended by striking ‘‘(a)(1)(B)’’ and inserting ‘‘(a)(2)’’.
(38) RETIREMENT SAVINGS.—
(A) Subparagraph (A) of section 219(b)(5) is amended
to read as follows:
‘‘(A) IN GENERAL.—The deductible amount is $5,000.’’.
(B) Clause (ii) of section 219(b)(5)(B) is amended to
read as follows:
‘‘(ii) APPLICABLE AMOUNT.—For purposes of clause
(i), the applicable amount is $1,000.’’.
(C) Paragraph (5) of section 219(b) is amended by
striking subparagraph (C) and by redesignating subparagraph (D) as subparagraph (C).
(D) Clause (ii) of section 219(g)(2)(A) is amended by
striking ‘‘for a taxable year beginning after December 31,
2006’’.
(E) Section 219(g)(3)(B) is amended by striking clauses
(i) and (ii) and inserting the following:
‘‘(i) In the case of a taxpayer filing a joint return,
$80,000.
‘‘(ii) In the case of any other taxpayer (other than
a married individual filing a separate return),
$50,000.’’.
(F) Paragraph (8) of section 219(g) is amended by
striking ‘‘the dollar amount in the last row of the table
contained in paragraph (3)(B)(i), the dollar amount in the
last row of the table contained in paragraph (3)(B)(ii),
and the dollar amount contained in paragraph (7)(A),’’ and
inserting ‘‘each of the dollar amounts in paragraphs
(3)(B)(i), (3)(B)(ii), and (7)(A)’’.
(39) REPORTS REGARDING QUALIFIED VOLUNTARY RETIREMENT CONTRIBUTIONS.—
(A) Section 219 is amended by striking paragraph (4)
of subsection (f) and subsection (h).
(B) Section 6652 is amended by striking subsection
(g).
(40) INTEREST ON EDUCATION LOANS.—Paragraph (1) of section 221(b) is amended by striking ‘‘shall not exceed’’ and all
that follows and inserting ‘‘shall not exceed $2,500.’’.
(41) DIVIDENDS RECEIVED ON CERTAIN PREFERRED STOCK;
26 USC 199.
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AND DIVIDENDS PAID ON CERTAIN PREFERRED STOCK OF PUBLIC
UTILITIES.—
(A) Sections 244 and 247 are hereby repealed, and
the table of sections for part VIII of subchapter B of chapter
1 is amended by striking the items relating to sections
244 and 247.
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(B) Paragraph (5) of section 172(d) is amended to read
as follows:
‘‘(5) COMPUTATION OF DEDUCTION FOR DIVIDENDS
RECEIVED.—The deductions allowed by section 243 (relating
to dividends received by corporations) and 245 (relating to
dividends received from certain foreign corporations) shall be
computed without regard to section 246(b) (relating to limitation
on aggregate amount of deductions).’’.
(C) Paragraph (1) of section 243(c) is amended to read
as follows:
‘‘(1) IN GENERAL.—In the case of any dividend received
from a 20-percent owned corporation, subsection (a)(1) shall
be applied by substituting ‘80 percent’ for ‘70 percent’.’’.
(D) Section 243(d) is amended by striking paragraph
(4).
(E) Section 246 is amended—
(i) by striking ‘‘, 244,’’ in subsection (a)(1),
(ii) in subsection (b)(1)—
(I) by striking ‘‘sections 243(a)(1), 244(a),’’ and
inserting ‘‘section 243(a)(1)’’,
(II) by striking ‘‘244(a),’’ the second place it
appears, and
(III) by striking ‘‘subsection (a) or (b) of section
245, and 247,’’ and inserting ‘‘and subsection (a)
or (b) of section 245,’’, and
(iii) by striking ‘‘, 244,’’ in subsection (c)(1).
(F) Section 246A is amended by striking ‘‘, 244,’’ both
places it appears in subsections (a) and (e).
(G) Sections 263(g)(2)(B)(iii), 277(a), 301(e)(2),
469(e)(4), 512(a)(3)(A), subparagraphs (A), (C), and (D) of
section 805(a)(4), 805(b)(5), 812(e)(2)(A), 815(c)(2)(A)(iii),
832(b)(5), 833(b)(3)(E), and 1059(b)(2)(B) are each amended
by striking ‘‘, 244,’’ each place it appears.
(H) Section 1244(c)(2)(C) is amended by striking ‘‘244,’’.
(I) Section 805(a)(4)(B) is amended by striking ‘‘,
244(a),’’ each place it appears.
(J) Section 810(c)(2)(B) is amended by striking ‘‘244
(relating to dividends on certain preferred stock of public
utilities),’’.
(K) The amendments made by this paragraph shall
not apply to preferred stock issued before October 1, 1942
(determined in the same manner as under section 247
of the Internal Revenue Code of 1986 as in effect before
its repeal by such amendments).
(42) ORGANIZATION EXPENSES.—Section 248(c) is amended
by striking ‘‘beginning after December 31, 1953,’’ and by
striking the last sentence.
(43) BOND REPURCHASE PREMIUM.—Section 249(b)(1) is
amended by striking ‘‘, in the case of bonds or other evidences
of indebtedness issued after February 28, 1913,’’.
(44) AMOUNT OF GAIN WHERE LOSS PREVIOUSLY DISALLOWED.—Section 267(d) is amended by striking ‘‘(or by reason
of section 24(b) of the Internal Revenue Code of 1939)’’ in
paragraph (1), by striking ‘‘after December 31, 1953,’’ in paragraph (2), by striking the second sentence, and by striking
‘‘or by reason of section 118 of the Internal Revenue Code
of 1939’’ in the last sentence.
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PUBLIC LAW 113–295—DEC. 19, 2014
128 STAT. 4045
(45) ACQUISITIONS MADE TO EVADE OR AVOID INCOME TAX.—
Paragraphs (1) and (2) of section 269(a) are each amended
by striking ‘‘or acquired on or after October 8, 1940,’’.
(46) MEALS AND ENTERTAINMENT.—Paragraph (3) of section
274(n) is amended—
(A) by striking ‘‘(A) IN GENERAL.—’’,
(B) by striking ‘‘substituting ‘the applicable percentage’
for’’ and inserting ‘‘substituting ‘80 percent’ for’’, and
(C) by striking subparagraph (B).
(47) INTEREST ON INDEBTEDNESS INCURRED BY CORPORATIONS TO ACQUIRE STOCK OR ASSETS OF ANOTHER CORPORATION.—
(A) Section 279 is amended—
(i) by striking ‘‘after December 31, 1967,’’ in subsection (a)(2),
(ii) by striking ‘‘after October 9, 1969,’’ in subsection (b),
(iii) by striking ‘‘after October 9, 1969, and’’ in
subsection (d)(5), and
(iv) by striking subsection (i) and redesignating
subsection (j) as subsection (i).
(B) The amendments made by this paragraph shall
not—
(i) apply to obligations issued on or before October
9, 1969 (determined in the same manner as under
section 279 of the Internal Revenue Code of 1986 as
in effect before such amendments), and
(ii) be construed to require interest on obligations
issued on or before December 31, 1967, to be taken
into account under section 279(a)(2) of such Code (as
in effect after such amendments).
(48) BANK HOLDING COMPANIES.—
(A) Clause (iii) of section 304(b)(3)(D) is repealed.
(B) The heading of subparagraph (D) of section
304(b)(3) is amended by striking ‘‘AND SPECIAL RULE’’.
(49) EFFECT ON EARNINGS AND PROFITS.—Subsection (d)
of section 312 is amended by striking paragraph (2) and redesignating paragraph (3) as paragraph (2).
(50) DISQUALIFIED STOCK.—Paragraph (3) of section 355(d)
is amended by striking ‘‘after October 9, 1990, and’’ each place
it appears.
(51) BASIS TO CORPORATIONS.—Section 362 is amended by
striking ‘‘on or after June 22, 1954’’ in subsection (a) and
by striking ‘‘, on or after June 22, 1954,’’ each place it appears
in subsection (c).
(52) TEMPORARY WAIVER OF MINIMUM REQUIRED DISTRIBUTION.—Section 401(a)(9) is amended by striking subparagraph
(H).
(53) INDIVIDUAL RETIREMENT ACCOUNTS.—Clause (i) of section 408(p)(2)(E) is amended to read as follows:
‘‘(i) IN GENERAL.—For purposes of subparagraph
(A)(ii), the applicable amount is $10,000.’’.
(54) TAX CREDIT EMPLOYEE STOCK OWNERSHIP PLANS.—Section 409 is amended by striking subsection (q).
(55) CATCH-UP CONTRIBUTIONS.—Clauses (i) and (ii) of section 414(v)(2)(B) are amended to read as follows:
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‘‘(i) In the case of an applicable employer plan
other than a plan described in section 401(k)(11) or
408(p), the applicable dollar amount is $5,000.
‘‘(ii) In the case of an applicable employer plan
described in section 401(k)(11) or 408(p), the applicable
dollar amount is $2,500.’’.
(56) EMPLOYEE STOCK PURCHASE PLANS.—Section 423(a)
is amended by striking ‘‘after December 31, 1963,’’.
(57) PENSION RELATED TRANSITION RULES.—
(A) Section 402(g)(1)(B) is amended by striking ‘‘shall
be’’ and all that follows and inserting ‘‘is $15,000.’’.
(B)(i) Subparagraph (D) of section 417(e)(3) is
amended—
(I) by striking clauses (ii) and (iii),
(II) by striking ‘‘if—’’ and all that follows through
‘‘section 430(h)(2)(D)’’ and inserting ‘‘if section
430(h)(2)(D)’’, and
(III) by striking ‘‘described in such section,’’ and
inserting ‘‘described in such section.’’.
(ii) Clause (iii) of section 205(g)(3)(B) of the Employee
Retirement Income Security Act of 1974 (29 U.S.C.
1055(g)(3)(B)) is amended—
(I) by striking subclauses (II) and (III),
(II) by striking ‘‘if—’’ and all that follows through
‘‘section 303(h)(2)(D)’’ and inserting ‘‘if section
303(h)(2)(D)’’, and
(III) by striking ‘‘described in such section,’’ and
inserting ‘‘described in such section.’’.
(C)(i) Paragraph (5) of section 430(c) is amended by
striking subparagraph (B) and by striking ‘‘(A) IN GENERAL.—’’.
(ii) Paragraph (5) of section 303(c) of the Employee
Retirement Income Security Act of 1974 (29 U.S.C. 1083(c))
is amended by striking subparagraph (B) and by striking
‘‘(A) IN GENERAL.—’’.
(D)(i) Paragraph (2) of section 430(h) is amended by
striking subparagraph (G).
(ii) Paragraph (2) of section 303(h) of the Employee
Retirement Income Security Act of 1974 (29 U.S.C. 1083(h))
is amended by striking subparagraph (G).
(E)(i) Paragraph (3) of section 436(j), as added by section 113(a)(1)(B) of the Pension Protection Act of 2006,
is amended by striking subparagraphs (B) and (C) and
by striking ‘‘(A) IN GENERAL.—’’.
(ii) Subparagraph (C) of section 206(g)(9) of the
Employee Retirement Income Security Act of 1974 (29
U.S.C. 1056(g)(9)) is amended by striking clauses (ii) and
(iii) and by striking ‘‘(i) IN GENERAL.—’’.
(F)(i) Section 436(j) is amended by striking the paragraph (3) added by section 203(a)(2) of the Preservation
of Access to Care for Medicare Beneficiaries and Pension
Relief Act of 2010.
(ii) Section 206(g)(9) of the Employee Retirement
Income Security Act of 1974 (29 U.S.C. 1056(g)(9)) is
amended by striking subparagraph (D).
(G)(i) Section 436 is amended by striking subsection
(m).
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26 USC 423.
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PUBLIC LAW 113–295—DEC. 19, 2014
128 STAT. 4047
(ii) Section 206(g) of the Employee Retirement Income
Security Act of 1974 (29 U.S.C. 1056(g)) is amended by
striking paragraph (11).
(H) Section 457(e)(15)(A) is amended by striking ‘‘shall
be’’ and all that follows and inserting ‘‘is $15,000.’’.
(58) LIMITATION ON DEDUCTIONS FOR CERTAIN FARMING.—
(A) Section 464 is amended by striking ‘‘any farming
syndicate (as defined in subsection (c))’’ both places it
appears in subsections (a) and (b) and inserting ‘‘any taxpayer to whom subsection (d) applies’’.
(B)(i) Subsection (c) of section 464 is hereby moved
to the end of section 461 and redesignated as subsection
(j).
(ii) Such subsection (j) is amended—
(I) by striking ‘‘For purposes of this section’’ in
paragraph (1) and inserting ‘‘For purposes of subsection
(i)(4)’’, and
(II) by adding at the end the following new paragraphs:
‘‘(3) FARMING.—For purposes of this subsection, the term
‘farming’ has the meaning given to such term by section 464(e).
‘‘(4) LIMITED ENTREPRENEUR.—For purposes of this subsection, the term ‘limited entrepreneur’ means a person who—
‘‘(A) has an interest in an enterprise other than as
a limited partner, and
‘‘(B) does not actively participate in the management
of such enterprise.’’.
(iii) Paragraph (4) of section 461(i) is amended
by striking ‘‘section 464(c)’’ and inserting ‘‘subsection
(j)’’.
(C) Section 464 is amended—
(i) by striking subsections (e) and (g) and redesignating subsections (d) and (f) as subsections (c) and
(d), respectively, and
(ii) by adding at the end the following new subsection:
‘‘(e) FARMING.—For purposes of this section, the term ‘farming’
means the cultivation of land or the raising or harvesting of any
agricultural or horticultural commodity including the raising,
shearing, feeding, caring for, training, and management of animals.
For purposes of the preceding sentence, trees (other than trees
bearing fruit or nuts) shall not be treated as an agricultural or
horticultural commodity.’’.
(D) Subsection (d) of section 464 of such Code (as
redesignated by subparagraph (C)) is amended—
(i) by striking paragraph (1) and redesignating
paragraphs (2), (3), and (4) as paragraphs (1), (2),
and (3), respectively, and
(ii) by striking ‘‘SUBSECTIONS (A) AND (B) TO APPLY
TO’’ in the heading.
(E) Subparagraph (A) of section 58(a)(2) is amended
by striking ‘‘section 464(c)’’ and inserting ‘‘section 461(j)’’.
(59) DEDUCTIONS LIMITED TO AMOUNT AT RISK.—Subparagraph (A) of section 465(c)(3) is amended by striking ‘‘In the
case of taxable years beginning after December 31, 1978, this’’
and inserting ‘‘This’’.
(60) PASSIVE ACTIVITY LOSSES AND CREDITS LIMITED.—
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128 STAT. 4048
(A) Section 469 is amended by striking subsection (m).
(B) Subsection (b) of section 58 is amended by adding
‘‘and’’ at the end of paragraph (1), by striking paragraph
(2), and by redesignating paragraph (3) as paragraph (2).
(61) ADJUSTMENTS REQUIRED BY CHANGES IN METHOD OF
ACCOUNTING.—Section 481(b)(3) is amended by striking
subparagraph (C).
(62) EXEMPTION FROM TAX ON CORPORATIONS, CERTAIN
TRUSTS, ETC.—Section 501 is amended by striking subsection
(s).
(63) REQUIREMENTS FOR EXEMPTION.—
(A) Section 503(a)(1) is amended to read as follows:
‘‘(1) GENERAL RULE.—An organization described in paragraph (17) or (18) of section 501(c), or described in section
401(a) and referred to in section 4975(g) (2) or (3), shall not
be exempt from taxation under section 501(a) if it has engaged
in a prohibited transaction.’’.
(B) Paragraph (2) of section 503(a) is amended by
striking ‘‘described in section 501(c)(17) or (18) or paragraph (a)(1)(B)’’ and inserting ‘‘described in paragraph (1)’’.
(C) Subsection (c) of section 503 is amended by striking
‘‘described in section 501(c)(17) or (18) or subsection
(a)(1)(B)’’ and inserting ‘‘described in subsection (a)(1)’’.
(64) ACCUMULATED TAXABLE INCOME.—Paragraph (1) of section 535(b) and paragraph (1) of section 545(b) are each
amended by striking ‘‘section 531’’ and all that follows and
inserting ‘‘section 531 or the personal holding company tax
imposed by section 541.’’.
(65) DEFINITION OF PROPERTY.—Subsection (b) of section
614 is amended—
(A) by striking paragraphs (3)(C) and (5), and
(B) in paragraph (4), by striking ‘‘whichever of the
following years is later: The first taxable year beginning
after December 31, 1963, or’’.
(66) AMOUNTS RECEIVED BY SURVIVING ANNUITANT UNDER
JOINT AND SURVIVOR ANNUITY CONTRACT.—Subparagraph (A)
of section 691(d)(1) is amended by striking ‘‘after December
31, 1953, and’’.
(67) INCOME TAXES OF MEMBERS OF ARMED FORCES ON
DEATH.—Section 692(a)(1) is amended by striking ‘‘after June
24, 1950’’.
(68) SPECIAL RULES FOR COMPUTING RESERVES.—Paragraph
(7) of section 807(e) is amended by striking subparagraph (B)
and redesignating subparagraph (C) as subparagraph (B).
(69) INSURANCE COMPANY TAXABLE INCOME.—
(A) Section 832(e) is amended by striking ‘‘of taxable
years beginning after December 31, 1966,’’.
(B) Section 832(e)(6) is amended by striking ‘‘In the
case of any taxable year beginning after December 31,
1970, the’’ and inserting ‘‘The’’.
(70) CAPITALIZATION OF CERTAIN POLICY ACQUISITION
EXPENSES.—Section 848 is amended by striking subsection (j).
(71) TAX ON NONRESIDENT ALIEN INDIVIDUALS.—Subparagraph (B) of section 871(a)(1) is amended to read as follows:
‘‘(B) gains described in subsection (b) or (c) of section
631,’’.
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PUBLIC LAW 113–295—DEC. 19, 2014
128 STAT. 4049
(72) LIMITATION ON CREDIT.—Paragraph (2) of section
904(d) is amended by striking subparagraph (J).
(73) FOREIGN EARNED INCOME.—Clause (i) of section
911(b)(2)(D) is amended to read as follows:
‘‘(i) IN GENERAL.—The exclusion amount for any
calendar year is $80,000.’’.
(74) BASIS OF PROPERTY ACQUIRED FROM DECEDENT.—
(A) Section 1014(a)(2) is amended to read as follows:
‘‘(2) in the case of an election under section 2032, its
value at the applicable valuation date prescribed by such section,’’.
(B) Section 1014(b) is amended by striking paragraphs
(7) and (8).
(75) ADJUSTED BASIS.—Section 1016(a) is amended by
striking paragraph (12).
(76) PROPERTY ON WHICH LESSEE HAS MADE IMPROVEMENTS.—Section 1019 is amended by striking the last sentence.
(77) INVOLUNTARY CONVERSION.—Section 1033 is amended
by striking subsection (j) and by redesignating subsections (k)
and (l) as subsections (j) and (k), respectively.
(78) PROPERTY ACQUIRED DURING AFFILIATION.—Section
1051 is hereby repealed, and the table of sections for part
IV of subchapter O of chapter 1 is amended by striking the
item relating to section 1051.
(79) CAPITAL GAINS AND LOSSES.—Section 1222 is amended
by striking the last sentence.
(80) HOLDING PERIOD OF PROPERTY.—
(A) Paragraph (1) of section 1223 is amended by
striking ‘‘after March 1, 1954,’’.
(B) Paragraph (4) of section 1223 is amended by
striking ‘‘ ‘(or under so much of section 1052(c) as refers
to section 113(a)(23) of the Internal Revenue Code of
1939)’ ’’.
(C) Paragraphs (6) and (8) of section 1223 are repealed.
(81) PROPERTY USED IN THE TRADE OR BUSINESS AND INVOLUNTARY CONVERSIONS.—Subparagraph (A) of section 1231(c)(2)
is amended by striking ‘‘beginning after December 31, 1981’’.
(82) SALE OR EXCHANGE OF PATENTS.—Section 1235 is
amended—
(A) by striking subsection (c) and by redesignating
subsections (d) and (e) as subsections (c) and (d), respectively, and
(B) by striking ‘‘subsection (d)’’ in subsection (b)(2)(B)
and inserting ‘‘subsection (c)’’.
(83) DEALERS IN SECURITIES.—Subsection (b) of section 1236
is amended by striking ‘‘after November 19, 1951,’’.
(84) SALE OF PATENTS.—Subsection (a) of section 1249 is
amended by striking ‘‘after December 31, 1962,’’.
(85) GAIN FROM DISPOSITION OF FARMLAND.—Paragraph (1)
of section 1252(a) is amended—
(A) by striking ‘‘after December 31, 1969’’ the first
place it appears, and
(B) by striking ‘‘after December 31, 1969,’’ in subparagraph (A).
(86) TREATMENT OF AMOUNTS RECEIVED ON RETIREMENT
OR SALE OR EXCHANGE OF DEBT INSTRUMENTS.—Subsection (c)
of section 1271 is amended to read as follows:
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‘‘(c) SPECIAL RULE FOR CERTAIN OBLIGATIONS WITH
TO WHICH ORIGINAL ISSUE DISCOUNT NOT CURRENTLY
IBLE.—
‘‘(1) IN GENERAL.—On the sale or exchange
of debt
instruments issued by a government or political subdivision
thereof after December 31, 1954, and before July 2, 1982,
or by a corporation after December 31, 1954, and on or before
May 27, 1969, any gain realized which does not exceed—
‘‘(A) an amount equal to the original issue discount,
or
‘‘(B) if at the time of original issue there was no
intention to call the debt instrument before maturity, an
amount which bears the same ratio to the original issue
discount as the number of complete months that the debt
instrument was held by the taxpayer bears to the number
of complete months from the date of original issue to the
date of maturity, shall be considered as ordinary income.
‘‘(2) SUBSECTION (a)(2)(A) NOT TO APPLY.—Subsection
(a)(2)(A) shall not apply to any debt instrument referred to
in paragraph (1) of this subsection.
‘‘(3) CROSS REFERENCE.—For current inclusion of original
issue discount, see section 1272.’’.
(87) AMOUNT AND METHOD OF ADJUSTMENT.—Section 1314
is amended by striking subsection (d) and by redesignating
subsection (e) as subsection (d).
(88) ELECTION; REVOCATION; TERMINATION.—Clause (iii) of
section 1362(d)(3)(A) is amended by striking ‘‘unless’’ and all
that follows and inserting ‘‘unless the corporation was an S
corporation for such taxable year.’’.
(89) OLD-AGE, SURVIVORS, AND DISABILITY INSURANCE.—
Subsection (a) of section 1401 is amended by striking ‘‘the
following percent’’ and all that follows and inserting ‘‘12.4 percent of the amount of the self-employment income for such
taxable year.’’.
(90) HOSPITAL INSURANCE.—Paragraph (1) of section
1401(b) is amended by striking: ‘‘the following percent’’ and
all that follows and inserting ‘‘2.9 percent of the amount of
the self-employment income for such taxable year.’’.
(91) MINISTERS, MEMBERS OF RELIGIOUS ORDERS, AND CHRISTIAN SCIENCE PRACTITIONERS.—Paragraph (3) of section 1402(e)
is amended—
(A) by striking ‘‘whichever of the following dates is
later: (A)’’, and
(B) by striking ‘‘;or (B)’ ’’ and all that follows and
inserting a period.
(92) WITHHOLDING OF TAX ON NONRESIDENT ALIENS.—The
first sentence of subsection (b) of section 1441 and the first
sentence of paragraph (5) of section 1441(c) are each amended
by striking ‘‘gains subject to tax’’ and all that follows through
‘‘October 4, 1966’’ and inserting ‘‘and gains subject to tax under
section 871(a)(1)(D)’’.
(93) AFFILIATED GROUP DEFINED.—Subparagraph (A) of section 1504(a)(3) is amended by striking ‘‘for a taxable year
which includes any period after December 31, 1984’’ in clause
(i) and by striking ‘‘in a taxable year beginning after December
31, 1984’’ in clause (ii).
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26 USC 1314.
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PUBLIC LAW 113–295—DEC. 19, 2014
128 STAT. 4051
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(94) DISALLOWANCE OF THE BENEFITS OF THE GRADUATED
CORPORATE RATES AND ACCUMULATED EARNINGS CREDIT.—
(A) Subsection (a) of section 1551 is amended—
(i) by striking paragraph (1) and by redesignating
paragraphs (2) and (3) as paragraphs (1) and (2),
respectively, and
(ii) by striking ‘‘after June 12, 1963,’’ each place
it appears.
(B) Section 1551(b) is amended—
(i) by striking ‘‘or (2)’’ in paragraph (1), and
(ii) by striking ‘‘(a)(3)’’ in paragraph (2) and
inserting ‘‘(a)(2)’’.
(95) CREDIT FOR STATE DEATH TAXES.—
(A)(i) Part II of subchapter A of chapter 11 is amended
by striking section 2011 (and by striking the item relating
to such section in the table of sections for such subpart).
(ii) Section 2106(a)(4) is amended by striking ‘‘section
2011(a)’’ and inserting ‘‘2058(a)’’.
(B)(i) Subchapter A of chapter 13 is amended by
striking section 2604 (and by striking the item relating
to such section in the table of sections for such subpart).
(ii) Clause (ii) of section 164(b)(4)(A) is amended by
inserting ‘‘(as in effect before its repeal)’’ after ‘‘section
2604’’.
(iii) Section 2654(a)(1) is amended by striking ‘‘(computed without regard to section 2604)’’.
(96) GROSS ESTATE.—Subsection (c) of section 2031 is
amended by striking paragraph (3) and by amending paragraph
(1)(B) to read as follows:
‘‘(II) $500,000.’’.
(97)(A) Part IV of subchapter A of chapter 11 is amended
by striking section 2057 (and by striking the item relating
to such section in the table of sections for such subpart).
(B) Paragraph (10) of section 2031(c) is amended by
inserting ‘‘(as in effect before its repeal)’’ immediately before
the period at the end thereof.
(98) PROPERTY WITHIN THE UNITED STATES.—Subsection (c)
of section 2104 is amended by striking ‘‘With respect to estates
of decedents dying after December 31, 1969, deposits’’ and
inserting ‘‘Deposits’’.
(99) FICA TAXES.—
(A) Subsection (a) of section 3101 is amended by
striking ‘‘the following percentages’’ and all that follows
and inserting ‘‘6.2 percent of the wages (as defined in
section 3121(a)) received by the individual with respect
to employment (as defined in section 3121(b))’’.
(B)(i) Subsection (a) of section 3111 is amended by
striking ‘‘the following percentages’’ and all that follows
and inserting ‘‘6.2 percent of the wages (as defined in
section 3121(a)) paid by the employer with respect to
employment (as defined in section 3121(b)).’’.
(ii) Subsection (b) of section 3111 is amended by
striking ‘‘the following percentages’’ and all that follows
and inserting ‘‘1.45 percent of the wages (as defined in
section 3121(a)) paid by the employer with respect to
employment (as defined in section 3121(b)).’’.
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26 USC 1551.
26 USC
prec. 2010.
26 USC
prec. 2601.
26 USC
prec. 2051.
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